Legal Opinion

Estate of Regester v. Commissioner

United States Tax Court

Decided July 2, 1984No. Docket No. 730-82Published

Decedent owned a life estate in the income of certain trust property and also possessed a special power of appointment, exercisable inter vivos or by will, over the corpus. She exercised the special power of appointment during her lifetime. Held, decedent made a gift equal to the present value of the life income interest in the trust. Self v. United States, 135 Ct. Cl. 371, 142 F. Supp. 939 (1956), not followed.

1Opinion of the Court

Estate of Ruth B. Regester, Deceased, Charles Regester, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Regester v. Commissioner

Docket No. 730-82

United States Tax Court

83 T.C. 1; 1984 U.S. Tax Ct. LEXIS 53; 83 T.C. No. 1;

July 2, 1984. July 2, 1984, Filed

Decision will be entered for the respondent.

Decedent owned a life estate in the income of certain trust property and also possessed a special power of appointment, exercisable inter vivos or by will, over the corpus. She exercised the special power of appointment during her lifetime. Held, decedent…

2Cases cited8 opinions

  1. Bailey, Collector of Internal Revenue v. GeorgeSupreme Court of the United States · 1922
  2. Commissioner of Internal Revenue v. WalstonCourt of Appeals for the Fourth Circuit · 1948
  3. Hrobon v. CommissionerUnited States Tax Court · 1964
  4. Walston v. CommissionerUnited States Tax Court · 1947
  5. Self v. United StatesUnited States Court of Claims · 1956

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